https://www.taxtmi.com/caselaws?id=462542 The ITAT Amritsar allowed the assessee's rectification application under section 254. The tribunal had earlier enhanced disallowance from Rs. 92,92,170 to Rs. 3,28,67,765 by estimating magazine and journal expenses at 10% of total operating revenue, despite only the assessee filing an appeal against the AO's original disallowance. The tribunal acknowledged that under Hukumchand Mills Ltd precedent, the word "thereon" in section 33(4) restricts tribunal jurisdiction to the subject matter of appeal, limiting enhancement powers when the department hasn't appealed. The rectification was granted as the enhancement constituted a mistake apparent from record. en-us Mon, 17 Aug 2020 00:00:00 +0530 Fri, 27 Jun 2025 18:17:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462542 The ITAT Amritsar allowed the assessee's rectification application under section 254. The tribunal had earlier enhanced disallowance from Rs. 92,92,170 to Rs. 3,28,67,765 by estimating magazine and journal expenses at 10% of total operating revenue, despite only the assessee filing an appeal against the AO's original disallowance. The tribunal acknowledged that under Hukumchand Mills Ltd precedent, the word "thereon" in section 33(4) restricts tribunal jurisdiction to the subject matter of appeal, limiting enhancement powers when the department hasn't appealed. The rectification was granted as the enhancement constituted a mistake apparent from record. Case-Laws Income Tax Mon, 17 Aug 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462542